To win conviction, the government must prove not only that Snipes and company broke the law, but that they meant to.

Snipes' lawyers say he was a victim of bad financial advice, and sincerely believed he didn't have to pay the government anything.

Kahn is the alleged ringleader of a central Florida tax protest group called American Rights Litigators, then Guiding Light of God Ministries. Kahn, a former CPA who lost licenses to practice in Florida and Ohio, allegedly drew up Snipes' fraudulent refund claims.

Prosecutors say the actor was looking for a way to avoid increasing tax bills caused by his burgeoning movie success.